1. Purpose This policy protects Jadeer’s independence and objectivity and establishes how actual, potential, or perceived conflicts of interest are identified, disclosed, and managed. 2. What is a conflict of interest? A conflict arises where a financial, personal, or professional interest, or a duty to another client, may impair—or reasonably appear to impair—Jadeer’s impartiality. Examples include concurrent work for competing parties on the same matter, a team member’s financial interest, an influential personal relationship, a material gift, or reviewing work previously performed by Jadeer. 3. Screening and disclosure • Jadeer conducts proportionate conflict checks before accepting and during an engagement. • Team members must promptly disclose internally any known or potential conflict. • Where relevant to the client, Jadeer will disclose the nature of the conflict to the extent necessary while respecting duties of confidentiality owed to others. 4. Managing conflicts Depending on the circumstances, measures may include informed written consent, separate teams and information barriers, restricted access, recusal, independent review, modified scope, or declining or ending the engagement. Consent will not be relied upon where the conflict cannot be managed lawfully and professionally. 5. Competitors and information Jadeer may serve organizations in the same industry unless a contract or material conflict prevents it. Client information is never shared with another client, and no sector or market exclusivity is granted unless agreed in writing. 6. Gifts and benefits Gifts, hospitality, commissions, or benefits must not be offered or accepted where they could influence, or reasonably appear to influence, professional judgment or contracting decisions. 7. Reporting and review Potential conflicts may be reported to [email]. Jadeer will assess reports confidentially and impartially and take appropriate action. This policy is reviewed periodically and updated when needed.